Local Plan – Draft Plan Consultation 2016 BGP4 - Green Belt and District Open Land Background Paper on Green Belt and District Open Land

1.0 Introduction

1.1 In total, 92.4% of the land within Epping Forest District is currently within the Metropolitan Green Belt. Some release of Green Belt land will be necessary to meet the growth needs and aspirations of the District, as insufficient previously developed land outside of the Green Belt is available. A site selection process has identified the most appropriate sites to allocate in the Local Plan to deliver the development to meet objectively assessed housing and employment needs over the Plan period. The site selection exercise has been undertaken taking account of all relevant criteria identified in the Council's Site Selection Methodology and the Traveller Site Selection Methodology.1

1.2 The National Planning Policy Framework (NPPF) states (at paragraph 83) that, once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. The purpose of this paper is to explain the approach which the Council has taken to review existing Green Belt boundaries in the District and to identify the exceptional circumstances that justify the alteration of existing Green Belt boundaries to accommodate planned development.

1.3 As part of the overall process of preparing a new Local Plan, the Council has taken the opportunity to undertake a thorough review of existing Green Belt boundaries in the District. That review has identified a number of anomalies in the Green Belt, where inappropriate development has taken place over time, such that the land no longer fulfils the purposes of the Green Belt. This paper identifies the opportunities to alter existing Green Belt boundaries to address such anomalies, having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the Plan period.

1.4 The Draft Local Plan includes a proposal to introduce a new local land-use designation, namely, 'District Open Land' in the specific locations identified. The proposed designation of existing Green Belt land as 'District Open Land' arises where proposed alterations to existing Green Belt boundaries causes some Green Belt land currently in recreational, leisure or open space use to become vulnerable to inappropriate development proposals. Consequently, the Council proposes to remove this land from the Green Belt but afford it a level of local policy protection to retain its current function and to avoid its loss to alternative land uses.

2.0 National Planning Policy Framework and Case Law

2.1 Paragraphs 83–85 of the NPPF (see Appendix 1 to this Background Paper) provide the parameters for defining and reviewing Green Belt boundaries. The NPPF requires local planning authorities to demonstrate exceptional circumstances to justify any alteration to existing Green Belt boundaries, whether the proposal is to extend or diminish the Green Belt. There is no clear definition of what amounts to exceptional circumstances but case law

1 See Appendix A of the Site Selection Report http://eppingforest.consultationonline.co.uk/wp- content/uploads/sites/5/2016/08/Appendix-A-Site-Selection-Methodology.pdf

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is clear that any justification must be responsive to local conditions and take account of a range of factors.

2.2 National Planning Policy makes clear that the only mechanism for altering Green Belt boundaries is the review of a Local Plan. However, preparation of a Local Plan in itself, does not amount to exceptional circumstances. The courts have provided guidance on the relevant factors to take into account when seeking to demonstrate exceptional circumstances.

2.3 In Gallagher Estates v Solihull MBC2 the High Court identified the proper approach to demonstrating exceptional circumstances. Relevant points are summarised below:

 planning guidance is a material consideration for planning, plan-making and decision-taking, however, it does not have statutory force: the only statutory obligation is to have regard to relevant policies;  The NPPF allows for some review in detail of Green Belt boundaries through the new Local Plan process, but states that "the general extent of Green Belt’s across the country is already established";  paragraphs 83 and 84 of the NPPF ensure that sustainable patterns of growth should guide where any amendment to Green Belt boundaries take place;  the process of preparing a new Local Plan is not, in itself, sufficient to be regarded as an exceptional circumstance; other planning judgments must also be bought to bear; and  exceptional circumstances are required for any revision of a boundary, whether the proposal is to extend or diminish the Green Belt.

3.0 Exceptional Circumstances in Epping Forest District

3.1 The Council considers that, considered together, a number of factors demonstrate the exceptional circumstances to justify the proposed alterations to existing Green Belt boundaries within Epping Forest District. The District is to the north east of , bisected by the M25 and M11 motorways; it is bounded to the west by the Lee Valley and the London to Stansted/Cambridge railway line; to the south by the built extent of suburban London (within the London Boroughs of Redbridge and Waltham Forest); and to the north by the River Stort and the boundaries of . To the east and north-east, the character of the District changes markedly and becomes very rural in nature. As stated above, in total, 92.4% of the District is currently within the Green Belt, with the existing settlements being tightly defined by Green Belt boundaries. These detailed Green Belt boundaries were initially defined during the 1980s in a series of Local Plans that covered what is now Epping Forest District. There has been little change to Green Belt boundaries over time, with the currently adopted Local Plan (1998) introducing only minor alterations. The overall policy of development restraint has been successful in Epping Forest District.

3.2 Since the Local Plan was adopted in 1998, there has been a substantial change in emphasis on the delivery of new growth and the requirement to deliver that growth in a sustainable

2 Gallagher Estates v Solihull MBC [2014] EWHC 1283 (Admin) (30 April 2014), endorsed and upheld by the Court of Appeal: [2014] EWCA Civ 1610 (17 December 2014)

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manner. Previous higher-tier plans (County Structure Plans and Regional Strategies) have determined that Epping Forest District and other nearby Districts within the Green Belt, should continue to be treated as areas of development restraint. These plans are no longer in effect and each local planning authority is now required to determine its own Objectively Assessed Needs for housing (OAHN) and employment (OAEN) development.

3.3 In accordance with the duty to co-operate in section 33A of the Planning and Compulsory Purchase Act 2004, the Council has worked and continues to work in partnership with East Hertfordshire, Harlow and Uttlesford District Councils, to determine the appropriate level of growth across the Strategic Housing Market Area. The most recent Strategic Housing Market Assessment is dated September 20153 and identifies that the OAHN for Epping Forest District is 11,300 homes between 2011 and 2033. The Housing Background Paper BGP14 includes substantial detail on the evidence available to determine the most appropriate local plan housing requirement for the District and identifies the housing requirement for the Local Plan as 11,400 dwellings.

3.4 The level of need identified for Epping Forest District is not, in itself, a sufficient justification for amending Green Belt boundaries. Therefore, further analysis of the specific circumstances relating to the District is necessary.

3.5 The Council undertook an “Issues and Options” consultation in 2012,5 which considered different levels of possible housing growth that were relevant at the time. It also identified the opportunities for brownfield redevelopment that were known at that time. At that stage, it was clear that land available outside of the Green Belt was unlikely to be sufficient to meet the identified need. Nevertheless, taking proper account of consultation feedback, in parallel to its work on the Green Belt review, the Council has continued to explore whether additional opportunities to deliver growth are available on land outside of the Green Belt.

3.6 The Council has prepared a Green Belt Review in two stages. Stage 1 of the Green Belt Review (September 2015)6 considered all Green Belt land within the District, identifying the locations where the overall performance of existing Green Belt land against national planning policy for protecting Green Belt land was higher or lower. A number of areas were identified for further study which made a limited contribution to the Green Belt purposes set out in paragraph 80 of the NPPF, or are in close proximity to existing settlements where development allocations are more likely to be considered acceptable in sustainability terms. Stage 2 of the Green Belt Review (August 2016)7 considered the broad locations for further investigation in greater detail by subdividing the assessment parcels into smaller areas. This stage of the review has identified areas of the District where the Green Belt continues to perform very strongly against the purposes of including land within Green Belts, and areas where it performs less well.

3 Opinion Research Services West and East Hertfordshire Strategic Housing Market Assessment: Report of Findings September 2015 4 Epping Forest District Council Background Paper 1: Housing September 2016 5 Epping Forest District Council Issues & Options for the Local Plan: Community Choices 2012 6 Epping Forest District Council Green Belt Review: Stage 1 September 2015 7 LUC Green Belt Review: Stage 2 August 2016

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3.7 Extensive analysis of the existing settlements has been undertaken to identify the potential opportunities for new homes to be delivered outside of the Green Belt. Evidence on land availability is derived from:

 Strategic Land Availability Assessment (NLP, July 2016)  Settlement Capacity Assessment (Fregonese Associates, March 2016)  Report on Site Selection (ARUP, September 2016)

3.8 A detailed Site Selection exercise has been completed for sites that were known potentially to be available for accommodating housing, traveller and employment growth. The methodology for this project incorporates a clear hierarchy of approach to the location of new development with a clear preference for sites outside of the Green Belt in the first instance as per the box below:

 the sequential flood risk assessment – proposing land in Flood Zone 2 and 3 only where need cannot be met in Flood Zone 1;  allocating sites around Harlow, within the District, to support the London Stansted Cambridge Corridor  sites located on previously developed land within settlements (the Green Belt boundaries were used as a proxy since more detailed settlement boundaries are not designated);  sites located on open space within settlements where such selection would maintain adequate open space provision within the settlement; and  previously developed land within the Green Belt (in anticipation of the NPPF being updated to take account of the proposed changes published in December 2015). Greenfield/Green Belt land on the edge of settlements:  of least value to the Green Belt if the land meets other suitable criteria for development;  of greater value to the Green Belt if the land meets other suitable criteria for development; and  Of most value to the Green Belt if the land meets other suitable criteria for development. Agricultural land:  of Grade 4-5 if the land meets other suitable criteria for development  enabling small scale sites in smaller rural communities where there is local need

3.9 Evidence provided by the Green Belt Review (in particular, Stage 2) has been used to inform the Site Selection process. This detailed and comprehensive assessment has determined there is insufficient land available outside of the Green Belt to meet the development requirements of the District. The hierarchy contained within the Report on Site Selection is clear that avoiding development in the Green Belt where possible, and protecting high

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performing areas of Green Belt where this is not possible are key factors in the choices made.

3.10 In seeking to deliver the most sustainable form of development across the District, the Council has sought to focus an element of growth around the periphery of Harlow. This growth is being delivered in a coordinated manner in cooperation with the other Local Authorities within the Housing Market Area and relevant additional parties. Growth at Harlow both makes best use of the services and facilities available in the largest settlement in the Housing Market Area, but also aids Harlow District Council and the London Stansted Cambridge Corridor Core Area vision8 in meeting aspirations for growth and regeneration across the town. The scale of growth envisaged in and around Harlow will necessitate the delivery of significant elements of new infrastructure, which will be located within the Green Belt in Epping Forest District.

3.11 The Draft Local Plan proposes to allocate growth such that this enables the delivery of the required infrastructure in a sustainable and cohesive manner, alongside housing and economic growth. The case for growth in and around Harlow is made on a number of levels. The London Stansted Cambridge Consortium is clear in its support for growth of Harlow and the improvements to key infrastructure that this growth will deliver. This will include a new motorway junction (Junction 7A) for the M11 that would be constructed on Green Belt land within Epping Forest and Harlow Districts. Across the Housing Market Area partners, Harlow has long been identified as a key sustainable location for growth and regeneration, providing with it the opportunity to bring real benefits to existing and future residents and workers.

3.12 For the sites around Harlow and all other locations across Epping Forest District, the Council has applied a number of planning judgements in reaching conclusions on the sites that should be proposed for allocation in the Draft Local Plan. These judgements vary slightly in different locations around the District and are largely encompassed by the criteria used in the Site Selection exercise. A balance has been reached between protecting areas of high performing Green Belt land where possible, but also taking into account matters of sustainability, protection of the environment and landscape, seeking regeneration and delivery of required growth. In some instances, the planning judgement applied has resulted in sites with high performing Green Belt land being proposed for allocation. This is particularly the case for the proposed sites around Harlow, recognising its location as a substantial town in the Metropolitan Green Belt, and the opportunities arising to meet housing, employment and regeneration needs along with necessary infrastructure. For the reasons set out in paragraph 3.9 (above), the Council considers that these sites are the most appropriate to deliver an overall benefit in planning terms.

3.13 For the reasons set out above, the Council considers that the need to promote sustainable patterns of development to meet objectively assessed needs for development in the District over the Plan period requires some alteration of Green Belt boundaries and that failing to deliver development to meet those needs would not contribute to the achievement of sustainable development in accordance with national planning policy. Therefore, the Council considers that exceptional circumstances have been demonstrated to alter existing Green

8 See Chapter 3 paragraph 3.11 of the Draft Local Plan

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Belt boundaries as proposed in the Draft Local Plan. The alterations proposed amount to the loss of approximately 1.5% of the current land within the Green Belt.

4.0 Anomalies in the Green Belt

4.1 The Green Belt Review: Stage 2 ("Stage 2")9 report identifies a number of major and minor anomalies in the Green Belt, where change has taken place. The major anomalies are all locations where significant development has taken place. The Stage 2 report draws out that these locations may not continue to meet the purposes of the Green Belt. A more detailed assessment of these areas has been undertaken (Appendix 2), which has identified eight locations where it is considered appropriate that an alteration to the Green Belt boundary is made.

4.2 This assessment has taken into account the analysis provided by the Stage 2 report, and provides additional discussion and context to determine whether a change to the boundary should be proposed. Chapter 5 of the Draft Local Plan reflects these proposed alterations.

4.3 A total of 36 minor anomalies have been identified by the Stage 2 report. These largely comprise small-scale locations where the Green Belt boundary no longer follows a clear feature on the ground. In many cases, this is because back garden boundaries have been extended over time. It is not desirable to make small-scale alterations in locations such as these, as there would be little practical benefit in doing so.

5.0 District Open Land

5.1 Paragraph 77 of the NPPF (and associated guidance) sets out the circumstances in which Local Green Space can be designated. In considering proposed alterations to Green Belt boundaries, it has been determined that a Local Green Space designation is required to offer protection from development in some locations where exceptional circumstances have been demonstrated to alter existing Green Belt boundaries. In these locations it is proposed to designate these areas as 'District Open Land', where alterations to the Green Belt boundaries may cause land which is currently in recreational, leisure or open space use to become vulnerable to inappropriate development proposals. It is proposed to remove this land from the Metropolitan Green Belt but afford it a level of local policy protection to protect it from loss to alternative land uses.

5.2 The tests identified in the NPPF are:

 where the green space is in reasonably close proximity to the community it serves;  where the green area is demonstrably special to a local community and holds a particular local significance, for example because of its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its wildlife; and

9 LUC Green Belt Review: Stage 2 (Technical Annex) August 2016 http://eppingforest.consonline.isready.co.uk/wp-content/uploads/sites/5/2016/08/Chapter-3-Final- Draft-Stage-2-Report-August-2016-V3_REDUCED.pdf

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 where the green space concerned is local in character and is not an extensive tract of land.

5.3 The following assessment has been completed to determine the specific circumstances in respect of the areas considered to warrant additional policy protection within the Local Plan.

Area Proximity to community Local significance Local character

South of All land is within 360 m of There are a number of The land to the south Waltham the existing built edge of features within the of is Abbey, north Waltham Abbey, and proposed District Open contained by the of M25 provides a large Land to the south of existing built edge of proportion of the green Waltham Abbey. Town the town and the M25 space for the town. Mead recreation to the south. ground and playing The Town Mead fields in the west, recreation ground and moving towards the playing fields are allotments and approximately 28.8ha cemetery bordering in area, with the Sewardstone Road, nearby cemetery and and the informal open allotments amounting space and BAP habitat to approximately south of Honey Lane 2.6ha. The land to the towards the eastern south of Honey Lane edge of Waltham has an area of 42.8ha. Abbey. It is therefore The Recreation and proportionate to the Open Space Study size of Waltham (2012) identifies a Abbey, and could not number of the facilities be considered an in this broad area, and extensive tract of land. states that they all appear to be well used and in good condition

Recreational This area was designed Planned open space The area of land is space to the as part of the housing connected to the small in nature, north of scheme at Tempest development of covering 0.78ha in Tempest Mead, to provide access Tempest Mead, total. It was primarily Mead, North to open space for the providing recreational designed into the Weald local residents. This area value to the local housing scheme to also provides access to community. meet the immediate the open space to the open space east. It is within a few requirements of the metres of the houses to occupants of the the north of the estate. properties.

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5.4 Two areas in the District within the settlements of North Weald Bassett and Waltham Abbey are proposed for designation as District Open Land in the Draft Local Plan. These areas are shown in Chapter 5 of the Draft Local Plan, within the policies and maps for each settlement. The responses to the consultation on the Draft Local Plan and further evidence gathering may identify further areas that should also be considered for designation.

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National Planning Policy Framework (extract)

“83. Local planning authorities with Green Belts in their area should establish Green Belt boundaries in their Local Plans which set the framework for Green Belt and settlement policy. Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. At that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the plan period.

84. When drawing up or reviewing Green Belt boundaries local planning authorities should take account of the need to promote sustainable patterns of development. They should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary.

85. When defining boundaries, local planning authorities should:

 ensure consistency with the Local Plan strategy for meeting identified requirements for sustainable development;  not include land which it is unnecessary to keep permanently open;  where necessary, identify in their plans areas of ‘safeguarded land’ between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period;  make clear that the safeguarded land is not allocated for development at the present time. Planning permission for the permanent development of safeguarded land should only be granted following a Local Plan review which proposes the development;  satisfy themselves that Green Belt boundaries will not need to be altered at the end of the development plan period; and  define boundaries clearly, using physical features that are readily recognisable and likely to be permanent. “

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Major anomalies in the Green Belt (identified by Green Belt Review: Stage 2)

GB Review Revise Proposed new Additional designation Location Stage 2 Parcel LUC report findings Discussion & Justification GB boundaries required? Ref. boundary

Tempest 11.1 The modern (c.2000) Tempest Mead is a YES Continuation of existing District Open Land Mead, development at Tempest relatively dense form of boundary at Kiln designation required to North Mead, on the western edge development on the Road/former Central Line immediate north of Weald of the parcel, can be southern edge of North underpass along former Tempest Mead estate, considered an anomaly Weald village, sitting Central Line. Boundary south of Kings Head car which should be excluded between High Road and the turns north west along park/garden and Dukes from the Green Belt. The former Central Line, and eastern boundary of Close, bounded by railway line to the south and accessed via Station Road. Tempest Mead hedgerows and gardens hedgerow to the east would The developed area adjoins development to meet of properties on the form strong boundaries. The other developed areas to existing Green Belt northern edge of Tempest small, isolated area of open the west, with the eastern boundary at the eastern Mead. District Open land between Tempest boundary of the corner of Dukes Close. Land designation also Mead and the B181 High development being formed required for small area Road is considered to make by a strong, mature tree immediately south of little contribution to Green line. The developed area junction of Station Road Belt purposes. now in situ does not meet and Tempest Mead. any of the purposes of land

within the Green Belt. An appropriate defensible boundary is therefore the Central Line to the south, and the tree line to the east.

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GB Review Revise Proposed new Additional designation Location Stage 2 Parcel LUC report findings Discussion & Justification GB boundaries required? Ref. boundary The land currently undeveloped to the west of Station Road, and directly to the rear of the King's Head will also be removed from the Green Belt. In isolation, neither of these areas continue to meet the purposes of including land within the Green Belt.

The 16.1 The residential development A small number of homes at YES Adjustment to remove c. None Gables, at The Gables to the west of the eastern edge of the "The 4 homes to the east of Ongar the parcel is a developed Gables" development are "The Gables". area with a similar pattern, currently within the Green form and character to the Belt. They are part of the adjoining settlement to the housing estate and west. It therefore performs therefore do not meet the weakly against the purposes of the Green Belt. Purposes of Green Belt and A more appropriate long lacks openness, and should term boundary is to the rear therefore be considered as of these properties. a potential anomaly. The road which provides access to these dwellings, an extension of The Gables, separates the built development from an area of public recreational open

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GB Review Revise Proposed new Additional designation Location Stage 2 Parcel LUC report findings Discussion & Justification GB boundaries required? Ref. boundary space, and marks a stronger distinction between developed and open space than the hedgerow that separates it from sports pitches to the east.

Mill 23.5 The residential development Mill Grove has been built YES Hedgerow to rear of None Grove, along Mill Grove contains adjacent to the existing inset residential properties to High houses and roads of a from the Green Belt the south & east of Mill Ongar similar form and density to boundary. The development Grove. Boundary to be the existing settlement. This forms a continuation of the drawn tightly to south of area lacks openness and built form of the village village hall. Village hall performs weakly against along Mill Lane, and a long grounds to remain in GB. Green Belt Purposes. It term boundary is formed by should therefore be the outer edge of considered as a potential development to the eastern anomaly. The edges of edge. The density of gardens on the eastern side development and lack of of the development follow openness means that the the pre-existing boundary to area no longer meets the an open, grassland field. purposes of including land The southern limit of the within the Green Belt. development is dictated by floodplain, but hedgerow alongside a tributary of the River Roding forms the nearest distinct boundary.

Kensingt 33.1 Potential anomaly at The development at YES From Oak Hill Road, to None on Park, Kensington Park (recent Kensington Park in itself follow hedgerow to north

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GB Review Revise Proposed new Additional designation Location Stage 2 Parcel LUC report findings Discussion & Justification GB boundaries required? Ref. boundary Staplefor housing development) would not warrant a change of Kensington Park, follow d which is adjoined to the to the Green Belt boundary. road end/turning space at Abbotts main settlement and However, since the Green eastern end, mature extends development away Belt Review: Stage 2 report treeline to south of from the main road (the analysis was completed eastern-most property in B175 Oak Hill Road) in what further planning consent has Kensington Place, follow is currently a very linear been granted on the car hedgerow/treeline to rear settlement. It may create a park to the rear of the Royal of current PH car park. stronger Green Belt Oak public house, and pre- Rejoin existing GB boundary if the boundary application discussions are boundary at rear gardens was drawn around the edge currently on going for land of properties on Oak Hill of the development, immediately to the north Road. however, the dwellings west of the area subject to along Kensington Park are this consent. Taking all of set in large grounds and so these changes in do create more of a combination the area will transition to the countryside not meet the purposes of rather than having urban including land within the character. Green Belt. A more appropriate Green Belt boundary in this location would be around the development at Kensington Park and the rear of the Royal Oak.

Grange 35.6 The Grange Hill station / The development that has YES To remove developed None Manor, Froghall Lane area is a taken place on this land now area and cutting of the Adj developed area, but the means that the purposes of Central Line from the Grange pattern of development is the Green Belt are not met. Green Belt. Amend Station, distinct from residential A long term boundary can alignment from eastern

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GB Review Revise Proposed new Additional designation Location Stage 2 Parcel LUC report findings Discussion & Justification GB boundaries required? Ref. boundary Chigwell development to the south be achieved by bring the end of Mount Pleasant to and west, and is separated Green Belt boundary into follow line of mature from the former by Manor line with the extent of vegetation towards the Road and the latter by a belt development and Froghall east. GB boundary to of woodland alongside the Lane. align with northern extent railway line. Well-defined of Grange Manor vegetation along Froghall development and Froghall Lane defines the developed Lane to the east, rejoining area to the east edge and a Manor Road. hedgerow contains it to the north, but it sits within a larger field bounded by hedgerow which would be weakened as Green Belt should the existing boundary be moved north of Manor Road.

Debden 42.2 Debden Park High School in The school buildings were NO No change None Park the south western corner of identified as a possible High the parcel is a developed anomaly within the Green School, area adjacent to the existing Belt. The school buildings settlement edge. The school represent a large built form building lacks openness and in the Green Belt, but are lies adjacent to the built-up separated from the urban area, but is separated from edge by the allotments, it by a well-treed stream community orchard and which also marks the stream. There is no clear settlement edge to the defensible boundary around north. The school playing the school buildings, and to fields have a reasonably remove both the buildings

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GB Review Revise Proposed new Additional designation Location Stage 2 Parcel LUC report findings Discussion & Justification GB boundaries required? Ref. boundary strong hedge line boundary, and the playing fields from but adjusting the Green Belt the Green Belt would not be edge to exclude both the appropriate as the playing school and its playing fields fields continue to meet at would affect an area which least some of the purposes does make some of the Green Belt. contribution to Green Belt purposes.

Fallow 54.3 The Fallow Fields The gated estate is set back NO No change None Fields, residential estate to the and well screened from Loughton south of Loughton/ Debden High Road/A121, providing is a developed area with a the impression from public similar density and form to view points of a gap the main settlement. Its between Loughton and character and lack of Buckhurst Hill. This is the openness represent only gap of significance urbanising elements which between the two do not meet the Purposes of settlements, and to make an Green Belt and it should amendment to the Green therefore be considered as Belt boundary in this a potential anomaly. location would create a However its physical further inset, which would separation from both not be desirable nor Buckhurst Hill and appropriate. Loughton, and containment by tree belts, mean that any amendment to the Green Belt would either be isolated or would require release of open land which makes

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GB Review Revise Proposed new Additional designation Location Stage 2 Parcel LUC report findings Discussion & Justification GB boundaries required? Ref. boundary some contribution to Green Belt purposes.

Davenan 54.6 The Davenant Foundation Davenant Foundation NO No change None t School buildings in the north School sits to the north of Foundati western corner of the parcel Loughton, adjoining the on constitute a developed area existing Green Belt School, adjacent to the existing boundary that runs along Loughton settlement edge, lacking in the residential properties to openness. A hedgerow the north of Grosvenor Drive creates some separation and Willingale Road. There from the settlement but are potential long term Debden Lane to the north of boundaries to the west and the school forms a stronger north of the school boundary. The school buildings, but an appropriate playing fields, subdivided by boundary does not exist hedgerows, retain openness between the buildings and and make some contribution the playing fields. It would to Green Belt purposes. An not be appropriate to access road, with adjacent remove the playing fields parking areas, separates from the Green Belt, and the school from the playing therefore no change is fields to the south-east, and recommended. a treed hedgerow separates it from the fields to the north-east.

Gilwell 59.2 The developed area at This developed area adjoins YES Realign GB boundary to Further check - some Hill, Gilwell Hill is of a density the built edge of follow extent of residential area of local green space Chingfor and pattern such that it is to the south (outside of the development as defined may need to be related to the adjacent District), and would form an by Baden Drive and

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GB Review Revise Proposed new Additional designation Location Stage 2 Parcel LUC report findings Discussion & Justification GB boundaries required? Ref. boundary d settlement to the south appropriate extension to the substantial hedgerow to designated. rather than the countryside. land inset from the Green north and hedgerow/tree The lack of openness Belt. The developed area is line to east. GB boundary means that it should be well contained from the to follow alignment of considered as a potential wider landscape by Sewardstone Road anomaly. A hedgerow forms hedgerows and trees to the (A112) to District a clear boundary between north and east. The boundary, crossing road this and the lakes and developed area does not at junction of grasslands of Picks Cottage meet the purposes of Sewardstone Fishery to the north. including land within the Road/Boardman Avenue. Green Belt.

Sainsbur 59.3 The parcel contains the Substantial change has YES Southern extent of District Open Land y’s Depot large Sainsbury’s depot taken place on the former development around designation required at & building, associated car/ Royal Ordnance site to the Meridian Way residential Town Mead, land west Housing, lorry parking and residential south of the M25, with the area and A121 Dowding and east of Sewardstone Waltham development. Although development of the Way. Green Belt Road (cemetery and Abbey separated from the rest of Sainsbury's distribution boundary to align with allotments respectively) Waltham Abbey by the M25, depot, business units, M25 (jct 26) off ramp and land to the south of the built development lacks approximately 400 dwellings leading to junction with Round Hills and Honey openness and the parking and the Gunpowder Park to Honey Lane. Lane. areas are too contained by the south. The developed development to retain any area immediately south of open relationship with the the M25 to the outer edge of countryside. It should the residential development therefore be considered as no longer meets the a potential anomaly. Strong purposes of the Green Belt. boundaries define this area: An appropriate long term the M25 to the north, the Green Belt boundary would A4112 Sewardstone Road be to the immediate south of to the east, the River Lea to the residential properties.

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GB Review Revise Proposed new Additional designation Location Stage 2 Parcel LUC report findings Discussion & Justification GB boundaries required? Ref. boundary the west and Gunpowder This adjustment also Park to the south. requires that land to the east of Sewardstone Road and north of Dowding Way is also considered against the purposes of the Green Belt. An allocation for employment development in this location is likely, and it would therefore be appropriate to consider the wider context. If development of a similar scale and nature to the Sainsbury's Distribution centre were to take place north of Dowding Way, the purposes of the Green Belt would no longer be met. In turn, the land to the north of the M25, immediately to the south of the current built edge of Waltham Abbey would therefore need to be reconsidered in Green Belt terms. No substantial change due to development is proposed in this broad location, with the exception of the redevelopment of the existing Waltham Abbey

October 2016 18 Epping Forest District Local Plan – Draft Plan Consultation 2016 BGP4 - Green Belt and District Open Land

GB Review Revise Proposed new Additional designation Location Stage 2 Parcel LUC report findings Discussion & Justification GB boundaries required? Ref. boundary Swimming Pool site. It is therefore proposed that a designation of District Open Land is applied to the land broadly bounded by the M25, the River Lea navigation, the southern edge of Waltham Abbey across the Honey Lane and junction 26 of the M25. This adjustment would ensure the long term suitability of the Green Belt boundary to the south of Waltham Abbey.

Beaulieu not within GBR2 Substantial developed area Development at Beaulieu YES To the west of Beaulieu None Drive, (outside area of adjacent to existing GB Drive is well contained by Drive, north of Hoppit Waltham search) boundary to west of Walton the River Lea on both east Road and across the Abbey Gardens, Leaview and and west, with each turning River Lea to the east, Flagstaff Road. Boundaries being gated from general adjoining the existing of developed area are well access. The development Green Belt boundary at defined by two sections of sits alongside the existing Flagstaff Road. the River Lea to the east Green Belt boundary at and west, and mature Flagstaff Close and planting to the immediate Leaview. The area of west of Beaulieu Drive. residential development Development extent to the does not meet the purposes north defined by Hoppit of the Green Belt, and the Road/access to the Royal River Lea to the west provides an appropriate

October 2016 19 Epping Forest District Local Plan – Draft Plan Consultation 2016 BGP4 - Green Belt and District Open Land

GB Review Revise Proposed new Additional designation Location Stage 2 Parcel LUC report findings Discussion & Justification GB boundaries required? Ref. boundary Gunpowder Mills Park. long term boundary.

Little 64.3 Houses along Little Brook Little Brook Road is a NO No change. None Brook Rd Road are of an age, density relatively dense form of Housing, and form that is considered development, but is well Roydon to represent an anomaly in contained by tree cover. Green Belt terms. There is Amendment to the Green only a short physical Belt boundary in this distance between the location would weaken the potential anomaly area and gap between the east of the existing inset boundary Roydon and the west of of Roydon, but a strong belt Harlow, and would likely of trees creates some lead to the further sprawl of separation and in visual the village itself into the land terms they have a contained between Grange Lane and setting, with reasonably Little Brook Road. The strong tree cover on all significant area of trees to sides. Although perception the west of Little Brook of housing in this area is Road continues to provide a limited, extending the Green long term defensible Green Belt boundary to include it Belt boundary. would reduce the defined gap between the built-up areas of Roydon and Harlow. It would also lengthen the already long Green Belt boundary around Roydon, which is weakened by number of turns it makes to follow the settlement form, and create a new

October 2016 20 Epping Forest District Local Plan – Draft Plan Consultation 2016 BGP4 - Green Belt and District Open Land

GB Review Revise Proposed new Additional designation Location Stage 2 Parcel LUC report findings Discussion & Justification GB boundaries required? Ref. boundary edge adjacent to further dwellings to both the east and north (across Harlow Road), raising the question of whether those houses ought also to be considered anomalous. This would also call into question the status of houses along the southern half of Grange Lane (in parcel 64.4 to the west). On balance the woodland between Little Brook Road and the built-up area as defined at present is probably a stronger boundary than that which would be created were Little Brook Road to be released from the Green Belt.

Paternos 68.1 The Paternoster Care Home The care home sits to the NO No change. None ter is a developed area rear of the houses on House adjoined to the existing Pasternoster Hill and Pick (Care settlement. The highlighted Hill. To the west is a large Home), area does not retain a glasshouse, which is an Waltham distinction between appropriate use in the Abbey settlement and countryside, Green Belt, and to the north and the built form does not west there is an area of maintain openness. Strong industrial and commercial hedgerows separate this uses accessed from Galley

October 2016 21 Epping Forest District Local Plan – Draft Plan Consultation 2016 BGP4 - Green Belt and District Open Land

GB Review Revise Proposed new Additional designation Location Stage 2 Parcel LUC report findings Discussion & Justification GB boundaries required? Ref. boundary area from commercial uses Hill. Although it is within the Green Belt off recognised that the care Galley Hill Road, a block of home itself is a large scrub woodland lies to the building in the Green Belt, east and the access road to the boundary to the rear of a large glasshouse defines the building appears no the western edge. This area stronger in Green Belt terms can therefore be considered than the existing boundary a potential anomaly. to the rear of the residential properties.

St John's 70.1 The buildings of St Johns The new development of NO No change. None School, School in the area between residential properties has Epping Bury Lane and Tower Road/ taken place outside of the Lower Swaines Road Green Belt, with the new constitute development that school buildings having abuts the built-up area edge been constructed on part of on two sides, although the existing playing fields hedgerows retain some within the Green Belt. separation. The open There is no long term playing fields to the north defensible boundary can still be considered to between the school make some contribution to buildings and the playing Green Belt purposes, but fields. The playing fields have strong outer still make a contribution to boundaries creating the Green Belt, and separation from the wider therefore it is not countryside. There are no appropriate to make any natural features to define a change in this location. boundary between the new school buildings and the

October 2016 22 Epping Forest District Local Plan – Draft Plan Consultation 2016 BGP4 - Green Belt and District Open Land

GB Review Revise Proposed new Additional designation Location Stage 2 Parcel LUC report findings Discussion & Justification GB boundaries required? Ref. boundary playing fields.

Teazle 70.5 The residential development Teazle Mead is a gated NO No change. None Mead, at Teazle Mead to the east development at the end of Thornwo of Thornwood is highlighted Carpenters Arms Lane. It is od as an anomaly because the adjacent to the existing density and character of Green Belt boundary around development in this location Thornwood, but represents and its relationship to the a small isolated extension adjacent settlement means into the Green Belt. that it is perceived as part of Amendment to the Green the settlement. It is Belt boundary is not contained by hedgerows. considered appropriate in this location.

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